Further guidance on the BBRS recent interpretation on building insulation
The Board of Building Regulations and Standards (“BBRS”) recently released an interpretation, which was entitled Utility-Sponsored and/or Other-Provided Minor Energy Efficiency Upgrades to Existing 1-4 unit homes (found at: http://www.mass.gov/eopss/docs/dps/buildingcode/inf4/bbrs-official-interpretation-no-2015-01.pdf).
In the days following the publication of this interpretation, this office has received many questions and concerns regarding the applicability of the interpretation, specifically when a permit is required and not required. The intent of the interpretation is to provide guidance regarding insulation (and other energy efficiency) upgrades where “no construction, reconstruction or alteration is taking place”.
With that said, any insulation upgrades that include work that does require a building permit (for example blown-in insulation that requires drilling through wall sheathing and/or gypsum board, or replacement of batt wall insulation that would require the removal of wall coverings) does require a building permit from the Building Official. The impact of this interpretation is that the addition of insulation into areas like cavities between ceiling joists in the attic, or exposed wall cavities in unfinished basements that do not require the removal of other coverings (primarily, wall and ceiling coverings) does not require a building permit.
More information about this can be found on the BBRS’ Frequently Asked Questions website (found at: http://www.mass.gov/eopss/consumer-prot-and-bus-lic/license-type/csl/building-code-one-and-two-family-dwelling.html).
Please feel free to call Felix Zemel at 617-826-5250 or email him at firstname.lastname@example.org if you have any additional questions and/or concerns.
Yes I agree because drilling and or replacement of batt wall insulation you need to remove drywall is considered construction.